Key takeaway
What This Development Means
China’s third batch of priority controlled chemicals expands regulatory oversight of PFAS and other hazardous substances across diverse industries. Businesses must prepare for tighter scrutiny, disclosure requirements, and operational safeguards to remain compliant.
What is the purpose of the Priority Controlled Chemicals List (Third Batch)?
The draft list identifies high-risk chemicals for stricter regulation to mitigate environmental and health threats. It includes substances with persistence, toxicity, and exposure potential, such as PFAS and phthalates.
How will this affect chemical manufacturers and downstream users?
Listed chemicals trigger compliance duties including EIAs, emissions tracking, and infrastructure safeguards. Companies must assess their product portfolios, supply chains, and processes for regulatory exposure.
Source basis: Source
China’s Ministry of Ecology and Environment (MEE) has released the draft Priority Controlled Chemicals List (Third Batch) for public consultation. Published on 21 November 2025, the draft identifies 64 substances with significant environmental and health risks, including 29 PFAS compounds. The consultation period runs until 2 December 2025.
This regulatory move aligns with China’s New Pollutants Control Action Plan and is expected to impact manufacturers, importers, and downstream users across multiple sectors, including petrochemicals, textiles, pharmaceuticals, plastics, coatings, and leather goods.
PFAS In The Crosshairs
A major feature of the draft is the inclusion of per- and polyfluoroalkyl substances (PFASs), known for their persistence, bioaccumulation, and resistance to degradation. PFASs are widely used in firefighting foams, stain-resistant textiles, non-stick coatings, and semiconductor manufacturing.
The draft list classifies PFASs under entry PC064, covering 29 individual substances such as perfluorobutanoic acid (PFBA), PFHxS-related compounds, and PFCAs with long-chain structures. Their inclusion follows increasing global scrutiny of PFAS due to their links to endocrine disruption, cancer, and environmental persistence.
High-Risk Phthalates And Industrial Solvents
The list also names high-use plasticisers such as di(2-ethylhexyl) phthalate (DEHP), dibutyl phthalate (DBP), and benzyl butyl phthalate (BBP), all of which are flagged for reproductive toxicity and endocrine disruption. Industrial solvents like 1,2-dichloroethane and 1,4-dichlorobenzene are also included, given their carcinogenicity and aquatic toxicity.
In total, the draft covers chemicals with carcinogenicity, mutagenicity, reproductive toxicity, endocrine-disrupting potential, or persistent bioaccumulative properties. The MEE used environmental monitoring data, exposure modelling, and toxicological studies to determine the list.
Regulatory Implications For Industry
Inclusion on the list triggers several regulatory obligations:
- Environmental Impact Assessments (EIA) for new projects must disclose quantities, uses, and transformation pathways of listed substances.
- Pollution Discharge Permits must detail substance composition in raw materials, based on design or actual values.
- Soil and Groundwater Protection measures are required for facilities handling listed substances, including corrosion prevention and leak detection systems.
Facilities must also prepare dismantling and pollution prevention plans prior to decommissioning operations involving listed substances.
Call To Action
Stakeholders across the chemicals value chain should review the draft list and assess potential compliance impacts. Comments must be submitted by 2 December to MEE via the provided contact details.
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